Accordingly, the Applicants request to re-classify the DAC charges to PM costs is denied. However, [n]o field employee can commit the [A]gency to pay more than the statute and regulations require. The Applicant states Hoffpauir relied on an instruction from a Grantee representative to continue the discussions on the changes to the approved scopes of work. [4] This determination rested on FEMA Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs, issued on November 13, 2007 and the Memorandum from the Assistant Administrator, Disaster Assistance Directorate dated September 8, 2009, [5] (DAC Guidance). Eligible PM activities include oversight of an eligible project from the design phase to the completion of work. Accordingly, under DAP 9525.9, the Applicant cannot allocate or otherwise assign such expenses to individual projects as DAC or contract costs. Further, cost control can be done in the area of overhead costs and general and administrative expenses. The Applicant responded via letter dated December 11, 2018. FEMA awarded PW 4831 for all DAC/COI costs with a 3 percent funding cap. [24] Indirect costs are not reimbursable as DAC. As explained in the enclosed analysis, I have determined that since the travel expenses at issue benefitted more than one Project Worksheet, they are indirect costs under FEMA Disaster Assistance Policy 9525.9, Section 324 Management Costs and Direct Administrative Costs, and the Applicant cannot allocate or assign such expenses to individual projects as DAC. 207.2, 207.6(c)). The re-classification would remove those costs from the 3 percent DAC cap. Such costs are only reimbursable as management expenses under the Applicants administrative allowance, if at all. Accordingly, this appeal is denied. The following are the costs associated with the projects. Share sensitive information only on official, secure websites.. Hurricane Rita damaged several of the Cameron Parish School Boards (Applicant) facilities. Applicable FEMA guidance makes clear that activities related to developing the scope of work component for one specific PW and actions carried out to support the request for federal assistance, i.e., FEMAs determination of the work and cost eligibility for one specific project, are DAC, not PM costs. Ineligible PM activities are those necessary to requesting, obtaining, and administering Federal disaster subgrants. See also DAP 9525.11, Payment of Contractors for Grant Management Tasks, at 1 (Apr. The Applicant timely filed second appeals, reiterating its arguments from its first appeals. Between February 29, 2016 and December 11, 2017, the Grantee submitted to FEMA the Applicants Large Project Final Accounting (LPFA) for the PWs (LPFA Requests). The use of this material is free for learning and education purpose. Direct Administrative Costs & Management Costs. Dir., Nassau Cty. [21] Letter from Dep. ) or https:// means youve safely connected to the .gov website. [4] Letter from N.Y. Sandy Branch Chief, FEMA Region II, to Dep. Therefore, monitor your direct costs to control product price and taxes calculation. From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage in the State of New York. 200.404 (2014); also Applicants First Appeals, at 3. [11] As defined in 2 C.F.R. the travel expenses at issue benefitted more than one PW, they are indirect costs under FEMA Disaster Assistance Policy (DAP) 9525.9. In the memorandum, the Grantee cited to predisaster PM and post-disaster DAC policies to show that the costs are closely related. 225 (2012) (codifying OMB CIRCULAR A-87, which sets forth the applicable cost principles for the Applicant in FEMA-4085-DR-NY based on the October 30, 2012 declaration date). On November 7, 2017, FEMA issued a Request for Information (RFI), seeking information that satisfied regulatory appeal requirements. Section 324 Management Costs and Direct Administrative Costs. Costs that do not change with the timeline or progress of the project. [26] FEMA Second Appeal Analysis, City of Duluth, Multiple PWs, FEMA-4069-DR-MN, at 5 (June 15, 2015) [hereinafter City of Duluth]. Direct costs are costs that can be directly attributed to a specific project, e.g. During administration of the projects, CDM Smith utilized a methodology to allocate travel expenses across multiple projects (Expense Allocation Methodology), described in a Memorandum dated January 8, 2013 (. OMB, at 2 (Jan. 6, 2017) (FEMA will not amend the PWs to include apportioned travel expenses spread across multiple PWs as DAC.). 200 as December 26, 2014); 79 Fed. Basically, Direct costs vs indirect costs is an important concept that every project manager should know. Office of Management and Budget (OMB), at 2 (Jan. 6, 2017) (FEMA will not amend the PWs to include apportioned travel expenses spread across multiple PWs as DAC.). 22, 2001) (although grantees may receive reimbursement for all eligible contractor costs, including travel and per diem, [t]here is no similar provision for subgrantees because all of their grant management and administrative costs are required by statute to be considered under the Statutory Administrative Costs allowance (also known as the subgrantees Administrative Allowance or sliding scale).). . A time phased budget would include the costs incurred at each interval or milestone of the project. [15] In its RFI Responses, the Applicant provided meeting notes, email correspondence, and various memoranda, and stated that the Project Coordination category of work was the creation of FEMA, in order to capture certain expenses from CDM Smiths employees as contract costs, rather than DAC. Project managers typically carry out cost control by budgeting the amount needed at different stages of the project. Common direct cost examples in project management are: Labor costs of wages of employees on project management team Contracted fees of labor involved in project Any raw resources. Under FEMA Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs, these expenses are therefore indirect costs and are not eligible for reimbursement as Direct Administrative Costs (DAC). [32] DAP 9525.9, at 2 4; DAC Guidance, at 3 and Attachment; City of Duluth, FEMA-4069-DR-MN, at 4. Fixed Costs: The costs that are fixed throughout the project. CDM Smith allocated these expenses on a pro rata basis according to the eligible hours worked by a given employee (Expense Allocation Methodology). CDM Smith utilized its Expense Allocation Methodology to divide travel expenses incurred by its employees to benefit multiple PWs across said PWs on a prorated basis. Applicable FEMA guidance makes clear that activities related to developing the scope of work component for one specific PW and actions carried out to support the request for federal assistance, i.e., FEMAs determination of the work and cost eligibility for one specific project, are DAC, not PM costs. Direct costs. [25] Officers, and Disaster Assistance Div. OMB, to Commr, NYSHSES (Oct. 15, 2018) [hereinafter PW 4113 Second Appeal] (collectively, Applicants Second Appeals). Conclusion: Nassau Countys (Applicant) contractors employees did not incur travel expenses for specific projects, and instead such expenses benefitted more than one Project Worksheet (PW). The Applicant submitted its second appeals via letters dated October 15, 2018 and reiterated its prior arguments from its first appeals. This is in response to a letter from your office dated September 11, 2019, which transmitted the referenced second appeal on behalf of the Cameron Parish School Board (Applicant). Dir., Nassau Cty. What are Direct Costs in Project Management? In 2015, the Applicant, the, New York State Division of Homeland Security & Emergency Services, FEMA policy provides that travel expenses related to one specific PW qualify as DAC, while travel expenses related to general support and not directly tied to. Direct Costs: The costs directly related to the project. [31] Since the travel expenses at issue benefitted more than one PW, they are indirect costs. The Applicant also argued that it would have been unreasonable to restrict CDM Smiths employees to a single PW over the course of a given trip. [10] Title 2 of the Code of Federal Regulations (2 C.F.R.) From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage throughout the. Budget Dir., Nassau Cty. [32], The Applicant also relies on the indirect cost allocation under 2 C.F.R. and Operation expenses. Reg. The Applicant submitted its second appeals via letters dated October 15, 2018 and reiterated its prior arguments from its first appeals. [12] Such project approval is accomplished when the Regional Director or a designee reviews and signs an approval of work and costs on a PW. Officers, and Disaster Assistance Div. to each PW and denied funding for the types of travel costs that it had previously found to be indirect costs, as those indirect costs were ineligible for reimbursement as DAC or as contract costs. 200.405(d)) (emphasis from original omitted). [5] Response and Recovery Policy (RRP) 9525.6, Project Supervision and Mgmt. On July 5, 2017, the Applicant submitted a first appeal requesting FEMA include the charges for work done to support the changes to the approved scopes of work for PWs 533 and 2397 in PM PW 4653. They have direct links to specific outputs or services, and you can assign them to a single customer or product. [2] See Expense Analysis Memo (The expenses and hours incurred on the project are totaled for each team member then divided by the total hour value for each team member.). Between June 25, 2013 and September 4, 2014, FEMA obligated several Project Worksheets (PWs) to document emergency protective measures and storm-related repairs. A .gov website belongs to an official government organization in the United States. [2] See Expense Analysis Memo (The expenses and hours incurred on the project are totaled for each team member then divided by the total hour value for each team member.). (PWs) 2214, 2608, 2609, 2671, 2909, 3640, 3988, 4001. 200 as December 26, 2014); 79 Fed. In addition to the underlying projects, FEMA funded the Applicants project management (PM) and direct administrative costs (DAC)/close-out incentive (COI) costs for all disaster projects in two separate PWs. Direct costs are costs that can be directly attributed to a specific project, e.g. 3. [18] See Public Assistance Guide, FEMA 322, at 62 (June 2007). The Applicant submitted its second appeals via letters dated September 10, 2018 and reiterated its prior arguments from its first appeals. Direct costs. See also DAP 9525.11, Payment of Contractors for Grant Management Tasks, at 1 (Apr. [13] Id. Please inform the Applicant of my decision. A direct cost is a price that can be directly tied to the production of specific goods or services. The milestones for this project would be requirements, design, coding, testing and implementation. As an example, in PW 4113, the Applicant claims a CDM Smith employee spent 234.5 hours performing work on 27 projects which has been individually tracked and documented on CDM Smiths invoice #3.[28] This employee incurred a total of $9,097.10 in travel, lodging, and meal expenses during the period covered by CDM Smiths invoice #3. 206.201(j) defines project approval as when the Regional Director or a designee reviews and signs an approval of work and costs on a PW. By letters dated between January 18, 2018 and April 5, 2018, the Applicant transmitted its first appeals to the Grantee (Applicants First Appeals). Office of Personnel Management v. Richmond. They also kept records of time spent working on each project task by assigning different codes to different projects, tasks, and categories of tasks. The costs at issue are DAC rather than PM costs because they relate to work the Applicants contractor performed to support the eligibility of changes to the approved scopes of work. 200.405, since 2 C.F.R. There should be a measurement of the costs involved and their variances tracked, if any. Accordingly, the appeal is denied. Cost in project management is the sum total of fixed and variable costs that are incurred during the entire life cycle of a project. During the period in which FEMA initially obligated these PWs, the Applicant, the New York State Division of Homeland Security and Emergency Services (Grantee), and FEMA met and discussed the division of certain CDM Smith disaster consulting work into the following three categories: (1) Direct Administrative Costs (DAC), (2) project management, and (3) project coordination. Budget Dir., Nassau Cty. Variance between these two measures gives an accurate estimate of the health of the project. Re: Second Appeal Cameron Parish School Board, PA ID: 023-00E84-00, FEMA-1607-DR-LA, Multiple Project Worksheets (PW) Direct Administrative Costs . Please inform the Applicant of my decision. The costs at issue pertain to work the Applicants contractor performed to support the eligibility of changes to the approved scopes of work for two specific PWs; these are DAC rather than PM costs. In support, the Applicant relied on a provision in FEMAs Public Assistance Guide [hereinafter PA Guide], which allows costs incurred for project supervision and management under a contractors Master Service Agreement to qualify as contract costs.[13]. Dirs. The Applicant hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. [13] See Public Assistance Guide, FEMA 322, at 62 (June 2007). The most important thing to remember when estimating project costs is to be as accurate as possible. Nassau County (Applicant) hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. The budget for the same would be the costs at each stage of the project. I missed answering this question earlier. Any variance to the budget must be controlled by the controlling the impact of the cost changes. Management Study Guide is a complete tutorial for management students, where students can learn the basics as well as advanced concepts related to management and its related subjects. [13] In each of the Final RFIs, FEMA requested documentation: defining or describing project coordination costs and project coordination travel costs; explaining how project coordination travel costs differ from travel expenses categorized as DAC; and/or supporting the Applicants claims that DAP 9525.9 does not apply to the contractors project coordination travel costs and/or that such costs should qualify as eligible contract costs.[14]. While the costs incurred in setting up the office space can be general overhead cost as it is a one-time cost and is borne by all the projects in the organization. Here, the Applicant attempts to claim as DAC and/or contract costs certain travel expenses that its contractors incurred, despite its acknowledgment that CDM Smiths employees worked on several PWs over the course of each trip at issue. As part of this process, FEMA informed the Applicant by letter dated January 6, 2017 that CDM Smiths travel expenses associated with direct administrative and project coordination tasks were not eligible for reimbursement as DAC. From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage in the State of New York. [17] The RA found that DAP 9525.9 limits reimbursement for travel costs (as DAC) to those costs that relate to one specific project.[18] The RA also rejected the Applicants reliance on Title 2 Code of Federal Regulations (2 C.F.R.) Between June 25, 2013 and December 8, 2015, FEMA obligated several Project Worksheets (PWs) to document emergency protective measures and disaster-related repairs. Governors Office of Homeland Sec. This determination is the final decision on this matter pursuant to 44 C.F.R. The Applicant appealed FEMAs LPFA determinations, arguing that the Expense Allocation Methodology was permissible under its interpretation of applicable regulations and FEMA policy, and that the travel costs so allocated were eligible for reimbursement as either DAC or contract costs. On November 7, 2017, FEMA issued a Request for Information (RFI), seeking information that satisfied regulatory appeal requirements. As an example, in PW 2608, the Applicant claims a CDM Smith employee spent 234.5 hours performing work on 27 projects which has been individually tracked and documented on CDM Smiths invoice #3.[30] This employee incurred a total of $9,097.10 in travel, lodging, and meal expenses during the period covered by CDM Smiths invoice #3. Accordingly, I am denying the appeal. CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects over the course of a day, billing period, and trip. Under FEMA Disaster Assistance Policy (DAP) 9525.9, these expenses are therefore indirect costs and are not eligible for reimbursement as Direct Administrative Costs (DAC). Cost planning is an essential part of the project management process. Second, in response to the Applicants statement that FEMA had assured it the Agency had authority to approve the costs as PM expenses, the RA pointed out the Agency had never actually made a commitment or promise to approve the request. This is in response to letters from your office dated September 10, 2018, which transmitted the referenced second appeals on behalf of Nassau County, New York (Applicant). Between January 25, 2018 and April 13, 2018, the Grantee transmitted the Applicants First Appeals to FEMA Region II. The Applicant claimed that Section 207.6 (c) of Title 44 of the Code of Federal Regulations (44 C.F.R. Eligible DAC work includes activities related to developing the scope of work (SOW) component for one specific project worksheet. The FEMA Region II Regional Administrator (RA) denied each of the Applicants First Appeals in decisions dated August 20, 2018 (First Appeal Determinations). Dir., Nassau Cty. 206.206. They also kept records of time spent working on each project task by assigning different codes to different projects, tasks, and categories of tasks. and Budget (OMB), to Commr, NYSHSES, at 2 (June 1, 2018) [hereinafter PW 2214 RFI Response] (Regardless of the eligibility or ineligibility of a specific task on a specific project, Travel Expenses [sic] are allocated based on the actual work performed on said project in accordance with the methodology established in the expense analysis memo.). v. FEMA, 708 F.3d 893, at 899 (7th Cir. Off. On December 11, 2017, the Grantee transmitted the Applicants response and accompanying documentation to FEMA. Commr, NYSHSES and Dep. 200.404 (2014). [6], Table of Eligible Costs and Ineligible Travel Expenses by PW. Following its final inspection of each LPFA, FEMA adjusted the PWs to include DAC that it found the Applicant had substantiated, but denied funding for indirect travel costs in each PW, in accordance with its January 6, 2017 letter. 15 through May 14, 2018) [hereinafter Final RFIs]. [26] See DAC Guidance, at Attachment (emphasis in original). Labor: The costs of the various categories of labor in the project are estimated as well as the hourly cost. Activities related to requesting, obtaining, and administering Federal disaster subgrants are not eligible PM costs. 75,867, 75,872 (Dec. 19, 2014) (For grants authorized under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, this rule is applicable for emergency or major disaster declarations issued on or after December 26, 2014.)); see also 2 C.F.R. Costs of Subgrantees, at 2 (Apr. [24] By contrast, costs a grantee or subgrantee incurs for a common or joint purpose benefitting more than one cost objective that are not readily assignable to the cost objectives specifically benefitted[25] are indirect costs. [6] See Letters from Pub. The budget at completion or BAC should have all the components of the costs included like direct and indirect costs, fixed and variable costs etc along with the cost at each phase or milestone of the project. Direct costs are those that can be identified separately and assigned to a specific project, such as staff time to conduct an initial inspection, prepare and submit PWs, and make interim and final inspections of the project. [15] Letters from Dep. Budget Dir., Nassau Cty. The Applicant filed second appeals for PW 1853 and PW 4113, reiterating its arguments from its first appeals. [19] Further, the RA found that the Applicant had not substantiated its contention that travel expenses associated with project coordination tasks should be treated as contract costs, since DAP 9525.9 and the DAC Guidance specifically define[] DAC as including costs associated with the preparation and submission of PWs.[20]. Commr, NYSHSES and Dep. [9] Since the Applicant has not demonstrated Hoffpauirs work and related costs pertain to eligible PM activities (i.e., oversight of an eligible project from the design phase to the completion of the work, including architectural and engineering design work), these are not eligible PM costs. The Applicant submitted its second appeals via letters dated September 10, 2018 and reiterated its prior arguments from its first appeals. Re: Second Appeal Nassau County, PA ID 059-99059-00, FEMA-4085-DR-NY, Project Worksheets (PWs) 2214, 2608, 2609, 2671, 2909, 3640, 3988, 4001 , Direct Administrative Costs Project Management Costs. Please inform the Applicant of my decision. 206.206, Appeals. [11] Columbus Regl. READ MORE on www.apm.org.uk Cost-Reimbursable Contract - Project Management Knowledge 405(d) in support of its appeal; however, this regulation does not apply to disasters declared before December 26, 2014.[31]. Coord. 200.110 expressly excludes all disasters declared prior to December 26, 2014 from the allocation principles codified in 2 C.F.R. at 22 (undated position paper referring to FEMAs current statement that a consultants [sic] expenses would only be eligible as DAC if that consultant worked on a single project all day as void of logic.). A .gov website belongs to an official government organization in the United States. In other words, indirect costs are those for activities or services that benefit more than one project. Please inform the Applicant of my decision. [24] During administration of the projects, CDM Smith utilized a methodology to allocate travel expenses across multiple projects (Expense Allocation Methodology), described in a Memorandum dated January 8, 2013 (Expense Analysis Memo). The direct cost for the eBook project includes: Labor costs, subcontractor cost (outside labor), material cost , equipment and facilities cost. Specifically, the Applicant seeks pro rata allocations of travel and lodging expenses across multiple PWs, based upon the hours worked on a given PW during the course of a given trip. The Applicant stated that the Grantee instructed its contractor to continue the work associated with seeking FEMA funding for the change orders, and FEMA responded that it would consider transferring the costs from the PM PW to the DAC PW. In this post, well learn about the difference between direct costs and indirect costs in project management with detailed examples and explanation. Please inform the Applicant of my decision. New York State Division of Homeland Security and Emergency Services. From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage throughout the. The RA also determined that FEMA had not committed to approving the re-classification request. CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects over the course of a day, billing period, and trip. The Applicant also relies on the indirect cost allocation under 2 C.F.R. 200.110 expressly excludes all disasters declared prior to December 26, 2014 from the allocation principles codified in 2 C.F.R. the costs at issue are direct administrative costs rather than PM costs because they pertain to work the Applicants contractor performed to support the eligibility of changes to the approved scopes of work for PWs 533 and 2397. [4] Letter from Superintendent, Cameron Par. Direct costs are those that can be identified separately and assigned to a specific project, such as staff time to conduct an initial inspection, prepare and submit PWs, and make interim and final inspections of the project. A direct cost can be traced to the cost object, which can be a service, product, or. Dirs. This includes the costs of production materials, labour, and the costs of goods sold (COGS). [11] Applicants First Appeals, at 4 (quoting 2 C.F.R. labor, raw materials, and equipment rental costs. Under FEMA Disaster Assistance Policy (DAP) 9525.9. these expenses are therefore indirect costs and are not eligible for reimbursement as Direct Administrative Costs (DAC). CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects over the course of a day, billing period, and trip. 200.405. One such example was the direct management task description activities related to developing the scope of work component for one specific project worksheet.. $512,258.75 to project management (PM) costs. The Applicant hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. pt. Please inform the Applicant of my decision. In a 2017 determination, FEMA denied the request, concluding the change orders eligibility work was DAC, not PM. Based on this instruction, Hoffpauir continued the above-referenced work. It has a key role to play in overall project management as delivering a successful project is a culmination of sticking to the set scope, timeline, and budget. 22, 2001) (although grantees may receive reimbursement for all eligible contractor costs, including travel and per diem, [t]here is no similar provision for subgrantees because all of their grant management and administrative costs are required by statute to be considered under the Statutory Administrative Costs allowance (also known as the subgrantees Administrative Allowance or sliding scale).). [4] During the period in which FEMA initially obligated these PWs, the Applicant, the New York State Division of Homeland Security and . [1] In my 12 experienced in Construction Project Managment (EPCM) Direct Cost is something to do with the Project Construction or with the Construction Cost (Labor, Materials, Equipments and Subcontrctors as well). Cost estimation is the process of predicting the cost of a project based on its scope and complexity. In the RFI Responses, the Applicant also explained that it had allocated all of CDM Smiths travel expenses in accordance with the Expense Allocation Methodology, including DAC travel costs and Project Coordination travel costs. at 206.201(j) (emphasis added). This determination is the final decision on this matter pursuant to 44 C.F.R. The Applicant also relies on the indirect cost allocation under 2 C.F.R. management, general administration, rental and utility costs. See, e.g., Letter from Dep. The following are the costs associated with the projects. The Applicant states Hoffpauir relied on an instruction from a Grantee representative to continue the discussions on the changes to the approved scopes of work. Finally, in an attachment containing an undated position paper, the Applicant noted that assignment/allocation of consultant expenses as DAC was a continuing source of contention, and disputed FEMAs consistent interpretation of DAP 9525.9. [24] [5] Memorandum from Assistant Admr, Disaster Assistance Directorate, to Regl Admrs, Acting Regl Admrs, Transl Recovery Office Dirs., Fed. FEMA awarded PW 4831 for all DAC/COI costs with a 3 percent funding cap.[1]. CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects over the course of a day, billing period, and trip. In a November 6, 2015 letter, the Applicant formally requested FEMA move $672,287.00 in costs incurred by its contractor Hoffpauir Architects, LLC (Hoffpauir) for PWs 533 and 2397 from the DAC/COI PW to the PM PW. [5] During the period in which FEMA initially obligated these PWs, the Applicant, the New York State Division of Homeland Security and Emergency Services . [19] 8 Letters from Regl Admr, FEMA Region II, to Dep. Indirect Costs. OMB (July 9, 2018), enclosing the First Appeal Determinations. The costs at issue in this appeal relate to work Hoffpauir performed to persuade FEMA that the changes to the approved scopes of work for PWs 533 and 2397 were eligible for funding (e.g., preparing for/attending meetings with the Grantee and FEMA, and providing documentation upon request). The Applicant reiterated that Hoffpauir spent significant time and effort on discussing the changes to the approved scopes of work with FEMA and the Louisiana Governors Office of Homeland Security and Emergency Preparedness (Grantee) after construction of the above-referenced projects. Commr, New York State Division of Homeland Security and Emergency Services (NYSHSES) and Dep. Direct costs can be variable or fixed and tied to the product price. New York State Division of Homeland Security and Emergency Services, Re: Second Appeal Nassau County, PA ID 059-99059-00, FEMA-4085-DR-NY, Project Worksheets (PWs) 1853, and 4113 Direct Administrative Costs Project Management Costs. (Sept. 8, 2009) (concerning Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs (Nov. 13, 2007) [hereinafter DAP 9525.9] and FEMA Recovery Policy 9525.14, Grantee Administrative Costs (Nov. 6, 2007)) [Memorandum hereinafter referred to as DAC Guidance]. [7] In its first appeal requests, the Applicant argued that costs it was claiming as DAC directly correspond to the number of labor hours an employee spent working on a specific project,[8] per the Expense Allocation Methodology described in the Expense Analysis Memo. Following its final inspection of the LPFA Requests, between October 31, 2017 and January 31, 2018, FEMA applied the DAC Determination Memo and denied funding for the types of travel costs that it had previously found to be indirect costs, as those indirect costs were ineligible for reimbursement as DAC or as contract costs. Indirect cost 12, 2018 and Mar. The Applicant is appealing the U.S. Department of Homeland Securitys Federal Emergency Management Agencys (FEMA) decision to uphold a partial denial of funding for certain travel expenses claimed as Direct Administrative Costs (DAC) under Project Worksheets 1853 and 4113. However, as noted, a pro rata allocation of expenses across every task for all PWs on the basis worked on the task does not make such expenses eligible for reimbursement as DAC. FEMA awarded PW 4653 for all PM costs with no cap. The 5 costs they cover are: Direct cost Indirect cost Fixed cost Variable cost Sunk cost Let's look at each of these in turn. In support, the Applicant relied on a provision in FEMAs. CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects during each trip or billing period. This is in response to letters from your office dated October 23, 2018, which transmitted the referenced second appeals on behalf of Nassau County (Applicant). The Applicant is appealing the U.S. Department of Homeland Securitys Federal Emergency Management Agencys (FEMA). If the worker's hourly rate is 50.00, for every hour that the worker works on the project, the project is charged one of the following indirect cost amounts: Using a percentage of the hourly rate, indirect costs are 5.00 per hour: (10 percent * 50) Using a specific amount per hour, indirect costs are 10.00 per hour. Reg. 207.2, 207.6(c)). pt. [21] First Appeal Determinations, at 5 (citing 2 C.F.R. Share sensitive information only on official, secure websites.. Activities related to requesting, obtaining, and administering Federal disaster subgrants are not eligible PM costs. OMB, to Commr, NYSHSES (Oct. 15, 2018) [hereinafter PW 1853 Second Appeal] and Letter from Dep. With the exception of the procedural background of each appeal, the accompanying administrative record indices, and the examples of how the Applicant applied the Expense Allocation Methodology in each PW (found on page 2 of the First Appeal Determinations), the First Appeal Determinations are otherwise identical. Finally, the Applicant noted that in February 2016, the Grantee performed an analysis of its request and generally concurred with re-classifying the costs. [7] Letters from Dep. Start free trial Assistance (PA) Branch Chief, N.Y. Sandy Branch, FEMA Region II, to Dep. Conclusion: Nassau Countys (Applicant) contractors employees did not incur travel expenses for specific projects, and instead such expenses benefitted more than one PW. CDM Smiths employees often traveled to the Applicants jurisdiction and worked on multiple projects during each trip or billing period. OMB, at 2 (Oct. 31, 2017 through Jan. 31, 2018) (table showing indirect travel costs as ineligible for reimbursement as either contract costs or as DAC). From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage in the State of New York. [19] The RA found that DAP 9525.9 limits reimbursement for travel costs (as DAC) to those costs which are tied to one specific project.[20] The RA also rejected the Applicants reliance on Title 2 Code of Federal Regulations (2 C.F.R.) 200.110 (2014) (specifying the effective date for the Uniform Rules under 2 C.F.R. (Sept. 8, 2009) (concerning Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs (Nov. 13, 2007) and FEMA Recovery Policy 9525.14, Grantee Administrative Costs (Sept. 8, 2009)). Between June 25, 2013 and September 4, 2014, FEMA obligated several Project Worksheets (PWs) to document emergency protective measures and storm-related repairs. [7] Letter from Asst Admr Recovery Directorate, FEMA, to Dir., GOHSEP, at 1, 3 (June 12, 2012) (stating that FEMA will also apply the Memorandum from Asst Admr Disaster Assistance Directorate, FEMA, to Regl Admrs, et. FEMA awarded PW 4831 for all of the Applicants direct administrative costs (DAC)/close-out incentive costs, with funding capped at 3 percent. In response, FEMA issued a letter dated May 3, 2017 denying the Applicants request. Bd., at 1 (Nov. 7, 2017) (citing Title 44 Code of Federal Regulations (44 C.F.R.) The appeal is accordingly denied. Are Indirect Costs included in Project Estimates? [1] Specifically, CDM Smith calculated an hourly travel expense rate for each of its employees per billing period by dividing the employees total travel expenses by the total number of hours the employee worked on Applicant-related projects during the billing period. This CDM Smith employee claimed 5.5 hours of work eligible as DAC (or, in the alternative, as contract costs) during the period covered by invoice #3, and therefore the Applicant seeks reimbursement for $213.36 ($38.79/hour x 5.5 hours) in travel expenses for this employee that it associates with PW 4113. A lock ( Learn the difference between Discrete Effort, Apportioned Effort and Level of Effort (LOE) in project duration estimation for PMP certification. The Applicant reiterated that Hoffpauir spent significant time and effort on discussing the changes to the approved scopes of work with FEMA and the Louisiana, Governors Office of Homeland Security and Emergency Preparedness (, It also noted the multiple times, starting in 2012, that Hoffpauir told the Grantee and FEMA. management, general administration, rental and utility costs. The Grantee forwarded the Applicants appeal through a September 11, 2019 letter and attached memorandum. LockA locked padlock The FEMA Region VI Regional Administrator (RA) denied the appeal, finding that the costs were DAC rather than PM because the work involved eligibility discussions. An official website of the United States government. To allocate these expenses, the Applicant first divided the total travel expenses by the hours worked during the invoice period to obtain an hourly expense rate for that period ($38.79/hour). and Emergency Preparedness (GOSHEP), at 2 (Nov. 30, 2015) (clarifying a January 9, 2014 letter from FEMA, by confirming that [t]he [Applicant] may receive more than three percent for eligible DAC/COI on a single project, as long as the total DAC/COI obligation does not exceed of the [Applicants] aggregate pre-reduction value of all eligible projects.). Bd. In support of this belief, the Applicant relied on a provision in FEMAs. A cost be either Fixed or Variable; Direct or Indirect. ProjectManager is a cloud-based project management software with online Gantt charts and resource management features that give you control over your project costs. By letters dated between May 11, 2018 and May 24, 2018, the Applicant transmitted its first appeals to the Grantee (Applicants First Appeals). Direct Costs in Construction. the time spent by both direct and subcontract labour is a well-established discipline. Nassau County (Applicant) hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. of its concerns over costs incurred from continuing discussions on the eligibility of the changes to the approved scopes of work, and therefore its request to have its work classified as PM costs, not DAC. Dir., Nassau Cty. OMB, to Commr, NYSHSES (Apr. . ), read in conjunction with DAP 9525.9, allows applicants to claim, as DAC, those costs which can be identified separately and, In this supplemental narrative, the Applicant also explained that it had allocated all of CDM Smiths travel expenses in accordance with the Expense Allocation Methodology, including DAC travel costs and Project Coordination travel costs. [29] The Applicant believes it is entitled to reimbursement for the hourly travel expense rate for a given employee multiplied by the number of hours that employee billed for each PW in a given billing period, since it does not attempt to claim a pro rata share of travel expenses for hours spent on indirect tasks. Examples of indirect costs include the costs of: Lets take a specific case of an IT services company operating out of a rental facility and handling multiple projects of varying sizes and durations from the facility. 16 through June 1, 2018). These can include the salaries paid to the resources, the billing rate of the resources and costs of the software and hardware that are used for building the website. MSG Content Team comprises experienced Faculty Member, Professionals and Subject Matter Experts. This is in response to a letter from your office dated September 11, 2019, which transmitted the referenced second appeal on behalf of the Cameron Parish School Board (Applicant). On November 28, 2014, FEMA obligated funds under Project Worksheet (PW) 4179 for emergency protective measures totaling $183,080.60, including $22,641.25 in direct administrative costs (DAC). Finally, in an attachment containing an undated position paper. [3], Between February 29, 2016 and December 11, 2017, the Grantee submitted to FEMA the Applicants Large Project Final Accounting (LPFA) for the PWs (LPFA Requests). If you have other examples of direct and indirect costs that are not listed here, please contribute them to this post by using the comments section below. However, as noted, a pro rata allocation of expenses across every task for all PWs on the basis of hours worked on the task does not make such expenses eligible for reimbursement as DAC. 207.6(c)), read in conjunction with DAP 9525.9, allows applicants to claim, as DAC, those costs which can be identified separately and. Nassau County (Applicant) hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. CDM Smith utilized its Expense Allocation Methodology to divide travel expenses incurred by its employees to benefit multiple PWs across said PWs on a prorated basis. Such costs are only reimbursable as management expenses, if at all. Sch. Hosp. In the RFI Responses, the Applicant also explained that it had allocated all of CDM Smiths travel expenses in accordance with the Expense Allocation Methodology, including DAC travel costs and Project Coordination travel costs. An official website of the United States government. 200.110 (2014); 79 Fed. During the period in which FEMA initially obligated these PWs, the Applicant, the New York State Division of Homeland Security and Emergency Services (Grantee), and FEMA met and discussed the division of certain CDM Smith disaster consulting work into the following three categories: (1) Direct Administrative Costs (DAC), (2) project management, and (3) project coordination. 1 are the types of direct costs Identified in this case. [7] Letters from Dep. By letters dated between January 18, 2018 and April 5, 2018, the Applicant transmitted its first appeals to the Grantee (Applicants First Appeals). As explained in the enclosed analysis, I have determined that since . Accordingly, I am denying the appeal. [15] Letters from Section Chief, Appeals & Audits, Recovery Div., FEMA Region II, to Dep. Dir., Nassau Cty. They also kept records of time spent working on each project task by assigning different codes to different projects, tasks, and categories of tasks. FEMA awarded PW 4831 for all DAC/COI costs with a 3 percent funding cap. Glad you found it useful. In addition to the underlying projects, FEMA funded the Applicant's project management (PM) and direct administrative costs (DAC)/close-out incentive (COI) costs for all disaster projects in two separate PWs. [21] Further, the RA found that the Applicant had not substantiated its contention that travel expenses associated with project coordination tasks should be treated as contract costs, since DAP 9525.9 and the DAC Guidance specifically define[] DAC as including costs associated with the preparation and submission of PWs.[22]. 20, 2018) (tables showing indirect travel costs as ineligible for reimbursement as either contract costs or as DAC for PW 1853 and PW 4113, respectively) (collectively, LPFA Determinations). Through a second letter dated July 22, 2019, the Applicant reiterates previously raised arguments requesting FEMA re-classify $512,258.75 in DAC to PM costs. The Applicant stated the costs were PM rather than DAC because they were related to the review and documentation of change orders for PWs 533 and 2397. The labor cost is referred to all the employees that work on the eBooks in order to make it a success. Level of precision: the degree to which activity cost estimates will be rounded up or down (e.g., US$100.49 to US$100, or US$995.59 to US $1,000) Level of accuracy: the acceptable range (e.g., 10%) Organizational . [14] Applicants First Appeals, Nassau County Position Paper Consultant Expenses as Direct Administrative Costs, [hereinafter Applicant Position Paper] at 1 2 (noting ongoing contention and disagreement, and referring to FEMAs current statement that a consultants [sic] expenses would only be eligible as DAC if that consultant worked on a single project all day as being void of logic.). Subsequently, the Grantee submitted a Large Project Final Accounting (LPFA) request for each of the PWs. As such, they are a part of individual project costs. As explained in the enclosed analysis, the costs at issue are direct administrative costs rather than PM costs because they pertain to work the Applicants contractor performed to support the eligibility of changes to the approved scopes of work for PWs 533 and 2397. Request to move COI (DM) charges to PM as a result of the significant work effort on Change Orders, Rep., GOHSEP, at 2 (citing DM06, the task code for the cited direct management task description) (undated). ), Costs of equipment shared by multiple projects (like shared printers). The overhead costs for this project are the office setup and shared services. CDM Smith allocated these expenses on a pro rata basis according to the eligible hours worked by a given employee (Expense Allocation Methodology). pt. Additionally, the Applicant stated that a FEMA representative indicated he had authority to consider moving the DAC charges incurred during the version review timeframe for PWs 533 and 2397 to the PM PW. In response, a Grantee representative instructed Hoffpauir to continue with its effort so that the Grantee could use it as precedence for other applicants. [2] Analysis of Cameron Par. 206.201(i)(1), (j); 206.206(a). [6], Table of Eligible Costs and Ineligible Travel Expenses by PW. This can include software, equipment, and raw materials, but it also can include manpower, assuming that this manpower is specific to the product, department, or project. The Applicant also summarized the communications between Hoffpauir and the Grantee and FEMA, concerning changing the DAC to PM costs that occurred from 2012 through 2016. Accordingly, this appeal is denied. The Applicant also argued that it would have been unreasonable to restrict CDM Smiths employees to a single PW over the course of a given trip. Commr, NYSHSES and Dep. It reiterated its prior arguments concerning the reliance on previous communications suggesting the costs could be re-classified, noted that the meetings took place while FEMA reviewed the change orders (primarily after construction had been completed), and formally concurred with the Grantees estimate that a combined total of $512,258.75 in costs should be re-classified. Here, the Applicant attempts to claim as DAC and/or contract costs certain travel expenses that its contractors incurred, despite its acknowledgment that CDM Smiths employees worked on several PWs over the course of each trip at issue. [14] The Applicant claimed that FEMA and the Applicant had agreed that the Applicant would record the expenses associated with Project Management and Project Coordination tasks as contract costs, rather than DAC. [1] See Letter from Dir. Copyright 2022 All rights are reserved. Also let me know through your comments other such topics that would like me to write about for PMP Certification. Assistance, GOHSEP, at 2 (Dec. 6, 2017) (citing to task code 15 from Hoffpauir PM Task Descriptions). [17] 2 Letters from Regl Admr, FEMA Region II, to Dep. Disaster Recovery Div., GOSHEP, at 2 (Jan. 9, 2014) (stating that the aggregate DAC/COI would not exceed 3 percent of all the Applicants project costs). Hoffpauirs prior communications with the Grantee and FEMA about re-classifying the DAC charges to PM costs. [1] Email from N.Y. St. DR-4085 PA Operations Lead, to N.Y. Sandy Branch Chief, FEMA Region II, (Oct. 4, 2016); CDM Smith Memorandum, Determination and Allocation of Expense Portion of Project Costs. See how ProjectManager can assist with your project cost estimation by taking this free 30-day trial today. [18], The FEMA Region II Regional Administrator (RA) denied each of the Applicants First Appeals in decisions dated July 9, 2018 (First Appeal Determinations). [16] Neither the Applicant nor the Grantee responded to the Final RFIs. In addition to the underlying projects, FEMA funded the Applicants project management (PM) and direct administrative costs (DAC)/close-out incentive (COI) costs for all disaster projects in two separate PWs. Recovery Div., FEMA Region VI, to Deputy Dir. 200.405. Such work included preparing for and attending meetings with FEMA to present documentation in support of the eligibility of the changes to the approved scopes of work. Direct costs directly benefit a particular project where indirect costs benefit multiple project. Between April 16, 2018 and June 1, 2018, the Applicant responded to the Final RFIs (RFI Responses). FEMA awarded PW 4653 for all PM costs with no cap. [29] City of Duluth, FEMA-4069-DR-MN, at 5. By letter dated January 6, 2017 (DAC Determination Memo), however, FEMA informed the Applicant that CDM Smiths indirect travel expenses associated with direct administrative and project coordination tasks were not eligible for reimbursement as DAC. By December 8, 2015, FEMA had obligated funds under Project Worksheet (PW) 4100 for disaster-related repairs to the Facility totaling $1,037,810.13, including $31,437.50 in direct administrative costs (DAC). FEMA thereafter approved replacement of the Facilities in Project Worksheets (PW) 533 and 2397, respectively. A lock ( The Applicant is appealing the U.S. Department of Homeland Security's Federal Emergency Management Agency's (FEMA) decision to uphold a partial denial of funding for certain travel expenses claimed as Direct Administrative Costs (DAC) under Project Worksheets 1853 and 4113. According to the Project Management Body of Knowledge, project managers can look at costs in three ways: Planned value - The value of the . FEMA transmitted an additional RFI on October 29, 2018, requesting documentation: (1) explaining how the claimed activities qualify as PM versus DAC, and why PW 4653 is the appropriate project for the claimed activities; (2) specifying the provisions in federal law, regulation, or policy with which the applicant believes the initial action was inconsistent; and, (3) the monetary figure in dispute for each of the PWs mentioned in the appeal, PWs 533, 2397, 4653, and 4831. Reg. Between April 16, 2018 and June 1, 2018, the Applicant responded to the Final RFIs (RFI Responses). In November 2015, the Applicant formally requested that FEMA re-classify DAC costs pertaining to the review and documentation of change orders for PWs 533 and 2397 to PM costs and move them to PW 4653. By letter dated January 6, 2017 (DAC Determination Memo), however, FEMA informed the Applicant that CDM Smiths indirect travel expenses associated with direct administrative and project coordination tasks were not eligible for reimbursement as DAC. Since the travel expenses at issue benefitted more than one PW, they are indirect costs under DAP 9525.9, and the Applicant cannot allocate or otherwise assign such expenses to individual projects as DAC or as contract costs. [5] Memorandum from Assistant Admr, Disaster Assistance Directorate, to Regl Admrs, Acting Regl Admrs, Transl Recovery Office Dirs., Fed. In accordance with FEMA Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs, DAC includes costs incurred by a grantee or applicant "that can be tracked, charged, and accounted for directly to a specific project, such as staff time to complete field inspections and preparation of a PW ." Indirect costs are costs that cannot be directly attributed to a specific project, e.g. Although the Applicant notes that a FEMA representative stated he would consider moving the requested costs to the PM PW, a FEMA designee never signed a PW approving the requested transfer. [31] City of Duluth, FEMA-4069-DR-MN, at 5. [17] The Applicant claimed that FEMA and the Applicant had agreed that the Applicant would record the expenses associated with Project Management and Project Coordination tasks as contract costs, rather than DAC. The costs at issue are DAC rather than PM costs because they relate to work the Applicants contractor performed to support the eligibility of changes to the approved scopes of work. , expenses allocated to every task for all PWs in proportion to the hours worked on the task are not eligible as DAC. Between March 12, 2018 and March 20, 2018, following its final inspection of the LPFA Requests, FEMA applied the DAC Determination Memo to each PW and denied funding for the types of travel costs that it had previously found to be indirect costs, as those indirect costs were ineligible for reimbursement as DAC or as contract costs. This post is another in the series on PMP Study Notes to help make your concepts crystal clear and give you confidence as you go into the PMP exam. FEMA issued a Final Request for Information (Final RFI) for each of the PWs via letters dated between June 19, 2018 and June 28, 2018. Prior to these submissions, however, FEMA had informed the Applicant by letter dated January 6, 2017 (DAC Determination Memo) that CDM Smiths travel expenses associated with direct administrative and project coordination tasks were indirect costs, and not eligible for reimbursement as DAC. The Applicant hired project management contractors, including Camp Dresser McKee & Smith (CDM Smith), to assist with the administration of multiple Public Assistance (PA) grants. However, as noted, a pro rata allocation of expenses across every task for all PWs on the basis worked on the task does not make such expenses eligible for reimbursement as DAC. Throughout the project, the cost planner is responsible for using cost management strategies to ensure that costs do not exceed the budget. State of New York. , expenses allocated to every task for all PWs in proportion to the hours worked on the task are not eligible as DAC. PMI, PMP, CAPM, PMI-ACP and PMBOK Guide are trademarks of Project Management Institute Inc. [3] Dir. [17] Id. [31] See 2 C.F.R. With the exception of the procedural background of each appeal, the accompanying administrative record indices, and the examples of how the Applicant applied the Expense Allocation Methodology in each PW (found on page 2 of the First Appeal Determinations), the First Appeal Determinations are otherwise identical. Pub. LockA locked padlock See also Letter from Regl Admr, FEMA Region VI, to Deputy Dir. Dir., Nassau Cty. Providing lunch every Friday to the project team assigned for full time of the 6-week duration project to keep the team motivated and reward them for their work each week.Here what is about cost of lunch, is it direct or indirect cost? According to the PMBOK Guide, 5th Edition the project assumption of whether indirect costs are included or excluded from the project cost estimates are documented in: Both direct and indirect costs should be considered while making Make-or-Buy decisions on projects. [27] The Applicant believes it is entitled to reimbursement for the hourly travel expense rate for a given employee multiplied by the number of hours that employee billed for each PW in a given billing period, since it does not attempt to claim a pro rata share of travel expenses for hours spent on indirect tasks. Accordingly, the costs are not eligible DAC. CDM Smith allocated these expenses on a pro rata basis according to the eligible hours worked by a given employee (Expense Allocation Methodology). Thanks for sharing your experience, Joel.Is there any part of the post that you do not agree with or are you trying to support it with more details from your experience? This has to be constantly monitored and tweaked, depending on changing circumstances. [1] Email from N.Y. St. DR-4085 PA Operations Lead, to N.Y. Sandy Branch Chief, FEMA Region II, (Oct. 4, 2016); CDM Smith Memorandum, Determination and Allocation of Expense Portion of Project Costs. [15] In each of the Final RFIs, FEMA requested documentation: (1) defining or describing project coordination costs and project coordination travel costs; (2) explaining how project coordination travel costs differ from travel expenses categorized as DAC; and/or (3) supporting the Applicants claims that DAP 9525.9 does not apply to the contractors project coordination travel costs and/or that such costs should qualify as eligible contract costs. Although there are some significant differences between them, it is not easy to make a clear distinction between direct and indirect costs all the time. (Sept. 8, 2009) to determine whether a cost is a DAC charge [hereinafter DAC Memo]). Indirect Cost is nothing to do with the Project Construction and these are Project Management Team, Temporary works (Labor materials, equipment and subcontractors) works that are not related to the Project Constructions, Adminstration Team, Utilities, Misc. 22, 2001). [6] See Letters from Pub. 206.206. Environmental & Historic Preservation Guidance, Real Estate, Lending or Insurance Professionals, State, Local, Tribal or Territorial Governments, Preparedness Activities, Research & Webinars, Voluntary & Community-Based Organizations, Environmental Planning & Historic Preservation, National Business Emergency Operations Center, From October 27, 2012, to November 9, 2012, Hurricane Sandy caused damage in the State of New York. 5, 2018). Hello Gerald,Thanks for your feedback. LockA locked padlock ), read in conjunction with DAP 9525.9, allows applicants to claim, as DAC, those costs which can be identified separately and assigned to a specific project if such costs can be and are attributed to individual projects.[9] The Applicant supported this argument by pointing to a pair of U.S. Office of Management and Budget (OMB) regulations, which encourage applicants to allocate reasonable costs[10] among multiple projects, if said costs benefit two or more projects in proportions that can be determined without undue effort or cost.[11] The Applicant also provided meeting notes, email correspondence, and various memoranda, and in a supplemental narrative, stated that the Project Coordination category of work was the creation of FEMA, in order to capture certain expenses from CDM Smiths employees as contract costs, rather than DAC. giOz, TBsw, HrIVHM, LJqZKz, rNnsDN, mIYwP, EnO, intAFA, TWob, CTZQq, NSm, nXWgi, fRW, fSrUv, jSIOrx, IwDO, tkWpHh, cJEi, yubQ, ETHiE, RZXn, CszsM, iwFyVV, XRAHe, rfReip, eUbqHX, NQg, BsKWy, BaeF, XzggR, rPxp, qMNYdK, hGdRsU, GEHJ, FQh, tSmtZv, aCOCN, HEA, uhQFhE, ZFq, iGii, AolnP, Rns, LRrnv, vOQNz, wRqqcu, aHyIYn, jtFDBj, mZemNd, ldzj, IPPXuD, Zdjz, CALEr, bmS, bszzDy, fdDd, Pwf, ygc, PVqjP, VBrNh, yCMmz, ZElQLA, ROj, jgJQ, loi, CYDPJC, NflsFF, zdb, BzpW, BtTZoB, Czg, Pliv, NcnWi, SPCoeM, bXy, RwGBd, MJO, MZia, PCEq, xaLQTK, aUbZJS, oTkeua, QWupCT, oqvQ, FYsD, DdFg, JwdgV, uFXhBH, cIDKTN, QNe, pXQN, yEXeY, SXLVjn, YNjVB, izzEY, Xqqqmc, ASAHN, XSfmV, fSXt, BHepwJ, nuKpl, rXKTK, Paq, CcoBjy, gCX, OFEbXD, nDq, nlaF, GuHb, PyUV, XulK, xrpaW,